Comment Analysis · Docket FS-2025-0001

FS-2025-0001-294236

Opposes rescissionA0 noneSubstance 7/24Posted August 31, 2026 On Regulations.gov

In short: The comment establishes that the Big Snowy Mountains, an Inventoried Roadless Area and Wilderness Study Area, lacks the economic resource values and access easements necessary to justify road construction, while citing a $7-11 billion deferred maintenance backlog to argue that rescinding the Roadless Rule will not achieve stated wildfire and forest health objectives.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A0 none: Counted, not answered.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Topics

  • Governance Policy Process
    • “attempt by the current administration to deregulate everything”
    • “top-down non-scientific based effort”
    • “allowing those on the ground decide local management”
  • Forest Management Wildfire
    • “Nor do I see the proclaimed objectives of new roads for better wildfire fighting access”
    • “backlog of 7-11 billion dollars in deferred road maintenance”
    • “deregulation will only exasperate this situation”
  • Environmental Protection Biodiversity
    • “Big Snowy Mountains which is an Inventoried Roadless Area”
    • “also a Wilderness Study Area (WSA)”
    • “removing the WSA designation”

What it names

Roadless areas
Wilderness Study Area

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Analytical gapEvidenceLegal

I am writing to voice my opinion that the Roadless Rule should not be rescinded! I view this as another attempt by the current administration to deregulate everything. Nor do I see the proclaimed objectives of new roads for better wildfire fighting access and forest health management being achieved. The U.S. Forest Service (FS) has a backlog of 7-11 billion dollars in deferred road maintenance and with a continuously declining budget deregulation will only exasperate this situation. Neither is there mention of increasing FS budgets to accomplish stated objectives. My backyard is the Big Snowy Mountains which is an Inventoried Roadless Area where road construction or reconstruction is not allowed and is also a Wilderness Study Area (WSA). At a recent public meeting to discuss removing the WSA designation, adjacent landowners to the forest supported this effort to promote logging which could reduce wildfire potential. Those landowners were asked if they would provide/sell an access easement across their properties to FS property, all declined. Nor are there any known resource values (timber, minerals, oil, or gas) of economic value that would justify road construction in difficult terrain there. In 2001, about 1.6 million public comments were received on the Roadless Rule – 90% of which were in support of it. A great example of allowing those on the ground decide local management. Rescinding the Roadless Rule is the opposite, a top-down non-scientific based effort. Again, I am asking that you not rescind the Roadless Rule! Thank you for allowing me to express my concerns and taking the time to read them.

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